Ellis Joey Boudreaux v. Ronald M. McArtor, 681 F. App'x 800

Ellis Joey Boudreaux was a Mary Ester firefighter promoted to Shift Captain (2010) and later transferred to Fire Inspector (Oct 2013), which he considered a demotion.
His mother, Judy Boudreaux, complained to the City Manager about nepotism and later filed an ethics complaint (Nov 19, 2013) alleging violations by the Fire Chief (Ronald McArtor), the Assistant Chief, the City Manager, and the City.
Before and after the ethics complaint, Boudreaux received multiple disciplinary actions, coaching forms, and complaints from other firefighters documenting substandard performance (Mar–Nov 2013 and post-complaint).
Chief McArtor sent the City Manager documentation criticizing Boudreaux’s ongoing poor performance and turned the matter over for "immediate and appropriate action." Boudreaux was terminated Jan 16, 2014; his internal appeal was denied.
Boudreaux sued under 42 U.S.C. § 1983 for First Amendment retaliation based on his mother’s speech and their association; the district court granted summary judgment to McArtor and the City, and the Eleventh Circuit affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether termination was unlawful First Amendment retaliation for mother’s protected speech/association	Boudreaux: termination was motivated by his mother’s ethics complaint and his association with her	City/McArtor: termination was for documented, ongoing substandard performance and loss of confidence	Held: No genuine issue that association was a motivating factor; plaintiff failed to show but-for causation, summary judgment affirmed
Whether McArtor is individually liable / whether qualified immunity applies	Boudreaux: McArtor acted to retaliate and should be personally liable	McArtor: qualified immunity shields him because no clearly established constitutional violation	Held: Qualified immunity applies because plaintiff failed to show deprivation of a constitutional right
Whether the City is liable (policy/custom/final policymaker/ratification)	Boudreaux: City Manager Oler was final policymaker or ratified McArtor’s recommendation, so municipal liability attaches	City: No unconstitutional decision; policymaking authority dispute irrelevant because no constitutional violation	Held: Municipal liability fails because no underlying constitutional violation; summary judgment for City

Johnson v. Bd. of Regents, 263 F.3d 1234 (11th Cir. 2001) (standards for de novo review of summary judgment)
Celotex Corp. v. Catrett, 477 U.S. 317 (1986) (summary judgment burden-shifting standard)
Am. Mfrs. Mut. Ins. Co. v. Sullivan, 526 U.S. 40 (1999) (§ 1983 requires deprivation of federal right)
Behrens v. Pelletier, 516 U.S. 299 (1996) (qualified immunity overview)
Roberts v. U.S. Jaycees, 468 U.S. 609 (1984) (freedom of association principles)
Pickering v. Bd. of Educ., 391 U.S. 563 (1968) (balancing public-employee speech/association interests)
Cuesta v. Sch. Bd. of Miami-Dade Cty., Fla., 285 F.3d 962 (11th Cir. 2002) (municipal liability: policy, custom, or final policymaker)